Wisconsin Ryan White Part B Eligibility and Recertification Policies and Procedures: Frequently Asked Questions

This policy applies to any services funded by Ryan White Part B funds or related funding in the state of Wisconsin except the AIDS Drug Assistance Program (ADAP) and Insurance Assistance Program (IAP). If you are unsure if this policy applies to your position or the services you provide, please consult with your supervisor.

Ryan White Part B services include over a dozen core medical and support services, including medical case management, outpatient ambulatory medical care, and housing services. These services are provided by clinics, community organizations, and medical centers across Wisconsin with funding and oversight from the Department of Health Services Division of Public Health. ADAP, including the Insurance Assistance Program (IAP), provides medication and insurance assistance, and is administered directly by the Department of Health Services Division of Public Health for all clients statewide. Both Ryan White Part B services and ADAP are funded with grants from the Health Resources and Services Administration HIV/AIDS Bureau (HRSA HAB).

The Wisconsin Communicable Disease Harm Reduction Section (CDHR), with guidance from the federal Health Resources and Services Administration, sets the income eligibility limit for Ryan White Part B services. The income limit for the ADAP and IAP is established by Wis. Stat. § 49.686 as 300% of the federal poverty level. A change to the ADAP and IAP income eligibility limit requires a change to the statutes through an act passed by the Wisconsin Legislature and signed by the Governor.

Part C and D funding recipients are responsible for outlining their own eligibility requirements in compliance with HRSA guidelines. If you have questions about services provided through Ryan White Part C or Part D, please consult with your HRSA HAB project officer.

Yes, as long as the document meets the requirements outlined in the policy.

Yes. Copies of these documents need to be retained. Copies of these documents can be kept as either physical copies or as electronic documents. If a diagnosis of HIV in an electronic medical record (EMR) is used to verify HIV diagnosis for eligibility, the subrecipient agency does not need to maintain a separate copy of this diagnosis as long as staff assessing a client’s eligibility continue to have the ability to view this diagnosis in the client’s EMR.

The Communicable Diseases Harm Reduction Section in the Division of Public Health, Wisconsin Department of Health Services, has been advised that we cannot offer guidance on whether accepting client signatures on behalf of the client is allowable. We urge subrecipient organizations to consult their legal department regarding this approach.

No. When you conduct the client’s annual eligibility confirmation, if the document you use has an issue date, the issue date should be no older than six months before the date you confirm eligibility.

Documents used to verify residency must show a client’s current residential address. Please see Appendix A.2 Acceptable Documents for Verifying Wisconsin Residency.

A person must reside in Wisconsin in order to be eligible for Ryan White-funded services. As residing in Wisconsin does not always mean receiving mail or having official documents with a Wisconsin address, we have included several options for clients to provide documentation from family members or roommates they live with, or for case managers to write an attestation of the client’s address.

Yes. A signed letter from a case manager attesting that the case manager has conducted a home visit and seen the client in their residence is an acceptable proof of residency document. This letter can be retained as either a physical or electronic copy and can be combined with other eligibility requirement attestations for Ryan White Part B Services, but must be easily located for auditing and quality review purposes.

Minor children should be included in the household of the parent with physical placement of the children. If the client has a court order that allows them to claim that child on their taxes, the child can be counted in the household size for the year following that tax submission.

Treat the client as uninsured and document accordingly in the client record. If billing a third party for services would require clients to disclose their HIV diagnosis to a family member or employer, Ryan White funds can be used to cover the costs of the client’s care. During annual eligibility confirmation, ask the client if their insurance information has changed as you would for any client to meet HRSA’s requirement of “vigorously pursuing” other funding sources. Also refer to Section 2.3.4 of the Wisconsin Ryan White Part B Eligibility and Recertification Policies and Procedures (P-02024): Recognizing Individualized Situations When Calculating Household Size and Household Income.

Clients who are college students should be documented either as their own household (if the client has their own insurance coverage) or as part of their parent or guardian’s household (if the parent or guardian claims the student as a dependent and/or the student is on the parent or guardian’s health insurance)

In some cases, there are legitimate reasons not to include one or more household member(s) and/or their income in household size and income calculations when determining client eligibility. Ryan White subrecipient agencies are expected to use their best judgement in relation to household size and household income requirements, and to consider the well-being of the client and the spirit of Ryan White legislation to provide services for people living with HIV who have lower incomes. The rationale for adjustments to the household size and household income calculations must be meticulously documented in the client record. Ryan White subrecipients are encouraged to contact the Wisconsin Communicable Disease Harm Reduction Section with questions regarding whether a client’s situation merits an adjustment to the household size and household income eligibility requirements.

Withdrawals from savings accounts do not count as income unless it would be reported as such on tax forms, such as withdrawals from a retirement savings account.

A one-time inheritance, or proceeds from the sale of an inherited asset, should not be considered income. Dividends and interest income from any inherited stocks, bonds, or investments should be counted as income. Income from a trust should also be counted as income.

Scholarships and proceeds from student loans do not count as income.

Yes. This qualifies as a change in income.

No. Public assistance that provides either cash assistance or in-kind benefits to individuals and families from a government agency, such as food assistance, utility assistance, or housing assistance, as well as any assistance from non-profit organizations, should not be included when calculating the client’s income. Please also see Section 2.3.3 of the Wisconsin Ryan White Part B Eligibility and Recertification Policies and Procedures (P-02024): Income Sources to Count Toward Household Income.

No. However, for subrecipients funded for any services that can be billed to insurance, it is strongly recommended to collect insurance information, even if the client only currently accesses services that cannot be billed to insurance.

The Ryan White Services Report (RSR) requires client income to be reported every year. However, if a client was eligible for Ryan White last year and attests their income has not changed, the client remains eligible for Ryan White. It is up to subrecipients to decide how to document this information for the RSR.

No. The requirement to ensure eligibility is on file before payments are made applies to Emergency Financial Assistance, Health Insurance Premium and Cost-Sharing Assistance, Housing, and Food Services (if vouchers are provided)

Yes. The requirement to ensure eligibility is on file before payments are made applies to Emergency Financial Assistance, Health Insurance Premium and Cost-Sharing Assistance, Housing, and Food Services (if vouchers are provided).

Yes, current Wisconsin Medicaid enrollment can be used to confirm both income eligibility and Wisconsin residency. Please see Appendix A.5 Acceptable Documentation of Enrollment in Another Government Program Requiring Wisconsin Residency and Income Below 500% FPL.

Yes, current Wisconsin Medicaid enrollment can be used to confirm both income eligibility and Wisconsin residency. Please see Wisconsin Ryan White Part B Eligibility and Recertification Policies and Procedures (P-02024), Appendix A.5: Acceptable Documentation of Enrollment in Another Government Program Requiring Wisconsin Residency and Income Below 500% FPL.

Yes. Subrecipients can also confirm the client is eligible for Ryan White services by verifying the client’s current enrollment in Medicaid, ADAP, SeniorCare, WIC, SNAP, HUD, or another government program that requires clients to reside in Wisconsin and have household income below 500% FPL, for which the client must submit proof of residency and proof of income. Proof of enrollment in a program that meets these requirements satisfies both the Ryan White residency requirement and the income requirement.

Yes. If a client’s name is incorrect in the ForwardHealth portal, subrecipient staff should document and explain any discrepancies between the ForwardHealth Portal and the subrecipient record for the client.

The information you are using to verify the client’s eligibility must be easily located for auditing and quality review purposes. Real-time data from insurance providers that is updated daily or on end-user demand in a medical record is acceptable verification of household income below 500% FPL and of residing in Wisconsin. In the scenario described above, we would advise the subrecipient to document the source of the eligibility data, the date it was verified, and other relevant information (such as client ID number) in the client record in a way that it can be easily located for auditing and quality review processes. If there is an audit trail where a reviewer can see what data was pulled from the ForwardHealth portal, this audit trail is sufficient; otherwise we would recommend taking and saving a screenshot of these data when using it to verify eligibility.

HRSA PCN 21-02 allows providers to use recent, reliable, and available data sources to verify income and residence. However, if the provider has confirmed that the information in a third-party data source is inaccurate, the provider must use other documentation or data sources to verify client eligibility. Services should not be discontinued to clients until there is a formal confirmation that the client has moved out of Wisconsin or has income above 500% FPL.

Discontinue services to the client when you become aware that the client is no longer eligible. You do not need to “back-date” the date the client became ineligible if you were unaware of the client’s ineligibility